Department of Energy (DOE) Operations & Proprietary Interests 

Santa Susana Field Laboratory (SSFL) 

Area I / Area IV 

Energy Technology Engineering Center (ETEC} 

Operations at The Bowl (Area I} to Support Area IV Programs 

Supportive Evidence: SEC Petition #0235 

Prepared for the Advisory Board on Radiation & Worker Health (ABRWH) and 

National Institute for Occupational Safety·& Worker Health 

CORE Advocacy for Nuclear & Aerospace Workers 

Prepared by: 

D'Lanie Blaze, CORE Advocacy for Nuclear & Aerospace Workers • COREAdvocacy.org 

Submitted Aug. 24, 2017 - NIOSH / ABRWH WG Meeting, Santa Fe, NM 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 1 of 30 
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DOE-ETEC Area I Operalions at The Bowl, SSFL Page 2 of 30 
ABRWH Advisory Board on Radiation and Worker Health 

ABTSWH Advisory Board on Toxic Substances and Worker Health 

AEC U.S. Atomic Energy Commission 

APTF Advanced Propulsion Test Facility 

Al Atomics International Division, North American Aviation 

Atomics International Atomics International Division, North American Aviation 

CDPHE California Department of Public Health and Environment 

co Contracting Officer 

CTL Components Test Laboratory 

DEEOIC Division of Energy Employee Occupational Illness Compensation 

D&D decontamination and decommissioning 

DD&D decontamination, decommissioning and demolition 

DHS Department of Health Services 

DOE U.S. Department of Energy 

DOD U.S. Department of Defense 

DOL U.S. Department of Labor 

DTSC CaJifomia Department of Toxic Substances Control 

EEOICPA Energy Employee Occupational Illness Compensation Program Act 

EPA U.S. Environmental Protection Agency 

EPIP Environmental Protection Implementation Plan 

ERDA Energy Research and Development Agency 

ETEC Energy Technology Engineering Center 

FAB Final Adjudication Branch 

FOIA Freedom of Information Act 

HSA Historical Site Assessment 

HQ headquarters 

IPDU 

LETF 

LLTR 

LMEC 

LMFBR 

MOU 

MSCG 

NASA 

NBZ 

NIOSH 

NRG 

ORISE 

PDU 

POC 

RIA 

RCRA 

LIST OF ACRONYMS & ABBREVIATIONS 

Integrated Process Development Unit 

Laser Engineering Test Facility 

Large Leak Test Rig 

Liquid Metal Engineering Center 

Liquid Metal Fast Breeder Reactor 

memorandum of understanding 

Molten Salt Coal Gasification 

National Aeronautics and Space Administration 

Northern Buffer Zone 

National Institute for Occupational Safety and Health 

Nuclear Regulatory Commission 

Oak Ridge Institute for Science and Education 

Plant Development Unit 

Probability of Causation 

radioactive 

Resource Conservation and Recovery Act 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 3 of 30 
RFI 

RHB 

SABER 

sen 

SCTL 

SB 

SBZ 

SC&A 

sen 

SCTL 

SHEA 

SPTF 

SRE 

SSFL 

SEM 

TM 

TO 

RCRA Facilily Investigation 

Radiological Heallh Branch 

Steam Accumulator Blowdown Evaluation Rig 

Sodium Components Test Installation 

Sodium Components Tesl Loop 

Senate Bill 

Soulhern Buffer Zone 

Sanford Cohen & Associates 

Sodium Componenls Test Installation 

Small Components Tesl Loop/ Laboralory 

Safety Heallh and Environmental Affairs 

Sodium Pump Tesl Facility 

Sodium Reactor Experiment 

Santa Susana Field Laboratory 

Site Exposure Matrix 

Technical Memorandum 

Task Order 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 4 of 30 
Introduction 

CORE Advocacy for Nuclear and Aerospace Workers respectfully submits the following information for 

review by the U.S. Department of Labor (DOL) Division of Energy Employee Occupational Illness 

Compensation (DEEOIC) and the U.S. Department of Energy (DOE). The purpose of this document is to 

provide DEEOIC and DOE with information to assist in determining that Santa Susana Field Laboratory 

(SSFL) Area I, The Bowl Energy Center (''The Bowl") fulfills legislative criteria under 42 USC § 73841 (a) 

and (b), and to establish DOE proprietary interests and operations that support the inclusion of SSFL 

Area I, The Bowl, as a "DOE Facility" and a "covered area" under EEOICPA. Additionally, this information 

establishes worker rotation between Areas I and IV of SSFL, and supports SEC Petition #0235. 

Although DOE operations and proprietary interests throughout SSFL Areas I, II and Ill are well 

documented throughout the site's official history, they have yet to be acknowledged under EEOICPA. 

Tllf,ffflnookl.AJ:lfclv11&'$8ullbil1-.i'iffillti\lln'lf/;l~ .. il~1',;~ffi'm':e.d area" and a DOE Facility under the Act. For 

purposes ieFatecrio this repoil;"liowever, on'fftl'/Jf:!. operations and proprietary interests at SSFL Area I, 

!'¥1,&~v,Wwftd1/Je'ii.1~11- on DOE-optioned land and allocated, in its entirety, to DOE and the Energy 

Technology Engineering Center (ETEC). 

• According to DOE documentation and contractual agreements referenced herein, DOE owned, 

operated and maintained a sufficient level of control of coal gasification and steam generator facilities 

located at The Bowl, which were considered by DOE to be Government Owned-Contractor Operated 

(GOCO) facilities . 

• ETEC operations at The Bowl supported and operated in conjunction with Area IV Molten Salt Coal 

Gasification (MSCG) programs, including the DOE Kalena / Power-PAK reactor program. 

, DOE-contractor employees performed job duties for DOE-ET EC at SSFL Area I, The Bowl, in service to 

DOE-sponsored programs . 

• SSFL Area I, The Bowl, fulfills legislative criteria under 42 USC § 73841 (a) and (b), and should be 

considered a DOE Facility. As such, SSFL DOE-contractor employees who performed job duties at the 

location should be considered eligible for EEOICPA. 

DOE operations at Area I were acknowledged by Sanford Cohen & Associates (SC&A) in 2008, in SC&A's 

Review of the NIOSH Site Profile for SSFL, prepared for the National Institute for Occupational Safety 

and Health (NIOSH). 1 According to SC&A: 

'The DOE had operations and facilities in Area I, as well as Area JV of the SSFL facility. However, 

no consideration has been given to potential exposure in Area I of SSFL, such as potential 

exposure for the coal gasification process." 

CORE Advocacy respectfully requests a detailed response to this submission from DEEOIC and DOE, 

and the opportunity to address any potential error, discrepancy or deficiency in the information provided 

herein. It is a privilege to submit the following information for review on behalf of SSFL personnel and 

EEOICPA claimants. 

1 S. Cohen & Associates (SC&A), "Review of/he NIOSH Site Profile for the Santa Susana Field Laboratoiy," Contract 

No. 200-2004-03805, Task Order 1: Draft Report SCA-TR-TASK1-0027. Document: sca-ssflsp-rOa.pdf (See pages 12 

& 48). 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 5 of 30 
CORE Advocacy for Nuclear and Aerospace Workers 

·coRE Advocacy for Nuclear & Aerospace Workers provides advocacy and Authorized Representation for 

Energy Employee Occupational Illness Compensation Program (EEOICPA) claimants of Santa Susana 

Field Laboratory (SSFL) and its associated facilities; Canoga, VanOwen, DeSoto, and Downey. 

CORE Advocacy is a member of the Alliance of Nuclear Worker Advocacy Groups (ANWAG), the Energy 

Employee Claimant Assistance Project (EECAP), and the former Division of Energy Employee 

Occupational Illness Compensation Interim Advisory Board (DIAB). CORE Advocacy participates in 

annual meetings attended by advocates and members of federal agencies tasked with EEOICPA's 

administration, and maintains an open dialogue with representatives of the federal agencies to continually 

assure accuracy and consistency in EEOICPA claim adjudication for SSFL personnel. 

CORE Advocacy's mission is to ensure transparency and full disclosure of SSFL site history to ensure 

that EEOICPA decisions are based on an accurate characterization of worker exposure. CORE 

Advocacy's research of SSFL site and contractor history is based strictly on official documentation 

created by DOE and its predecessor agencies and contractors, the National Aeronautics and Space 

Administration (NASA), Department of Defense (DOD), state and federal regulatory agencies, and 

employee records. 

Source Documents 

Documents cited in this submission were obtained from publicly accessible government databases, via 

the Privacy and Freedom of Information Acts (FOIA), from contractor and agency publications and 

reports, and employee records. Based on the origin of the source materials and their use by state and 

federal agencies and government contractors to verily employment, EEOICPA eligibility, and to chronicle 

site history, improve technology, establish site operations, and to guide environmental remediation of 

SSFL, it is reasonable to expect that DOE and DEEOIC will accept the source documents as credible. 

CORE Advocacy assumes no authorship or credit for the following information, nor makes any attempt to 

reinterpret any official document. Review of all source materials is encouraged to ensure accurate 

interpretation. CORE Advocacy has made every effort to appropriately credit sources and provides a 

comprehensive bibliography with a link to download all cited documents that are available. 

The Definition of a DOE Facility 

Under 42 U.S.C. § 73841 (12), a "DOE Facility'' is defined as any building, structure, or premise, including 

the grounds upon which such building, structure or premise is located -

(A) in which operations are, or have been, conducted by, or on behalf of the DOE (except for buildings, 

structures, premises, grounds or operations covered by Executive Order No. 12344, dated February 

1, 1982 (42 U.S.C. § 7158 note), pertaining to the Naval Nuclear Propulsion Program); and 

(8) with regard to which the DOE has or had 

i. a proprietary interest or 

ii. entered into a contract with an entity to provide management and operation, management and 

integration, environmental remediation services, construction, or maintenance services. 

The DEEOIC Procedure Manual (PM), Chapter 2-0500 indicates that evidence of DOE ownership of the 

building, structure or premises (such as a deed or affirmative statement from DOE acknowledging 

ownership), or contractual agreements showing that DOE had a sufficient level of use and control over 

the property may support a determination that the property constitutes a "DOE Facility." 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 6 of 30 
Contractor Obligations to Provide Information Under EEOICPA 

Boeing is under contract wtth DOE to maintain a Records Management Program and to conduct records 

inlormation content accountability in accordance with TIiie 44 USC, Chapters 21, 29, 31, 33 and 35; 36 

CFR, Chapter 12, Subchapter B (Records Management); DOE O 243.1 (Records Management Program) 

and DOE O 243.2 (Vital Records), and any other DOE requirements as directed by the Contracting 

Officer (CO). 

Boeing's contractual obligations include (but are not limited to) the storage, preservation and protection of 

active and inactive records; retrieval of records from on-and-off-site storage facilities; and supporting DOE 

records requests including ongoing FOIA requests, Privacy Act requests, EEOICPA and other programs. 

The contract does not specify or limit the types of information DOE may request or obtain from the 

contractor, and stipulates that Records Retention standards are applicable for the classes of records 

described in the contract, whether or not the records are owned by the Government or by the contractor.2 

SSFL Site Contract Allowed Contractor Use of Entire Facility for AEC Contract Fulfillment 

DEEOIC has established that the Atomic Energy Commission (AEC, DOE's predecessor agency) entered 

into a contract with the entire corporate entity of North American Aviation (NAA) on February 28, 1948. 

The contract expressly permitted NAA to apply its discretion in the use of any of its facilities, or those 

leased by the AEC, to perform functions affiliated wtth the fulfillment of its government contracts.3 

As Area IV did not formally exist in 1948, the original AEC-NAA contract did not contain a provision to limit 

or restrict AEC operations to Area IV. Rather, the contract specified that NAA could use any of its facilities 

in service to AEC. Early maps of SSFL suggest that Area IV may not have been formally incepted until the 

mid-to-late 1950's. Based on maps of site operations and the original facility contract that permitted NAA 

to utilize SSFL in its totality in service to .the AEC, AEC-DOE operations outside Area IV are not only 

reasonable and to be expected, but well documented by DOE, its predecessor agencies, and its 

contractors.• 

SSFL Site Description/ Corporate History 

The Santa Susana Field Laboratory (SSFL) is approximately 2,850 acres of rocky terrain, located in 

Ventura County, about 30 miles northwest of Los Angeles, California. SSFL is situated in the Santa 

Susana Mountains between the San Fernando and Simi Valleys. The site consists of four administrative 

areas - Areas I, II, Ill and IV, and two buffer zones; the Northern Buffer Zone (NBZ) and the Southern 

Buffer Zone (SBZ). The site progresses in an east-to-west direction, beginning with Area I and extending 

to Areas II, Ill and IV. Area IV is comprised of the site's westernmost 290 acres. 

SSFL's elevation is between 1,880 to 2,150 feet above sea level. The climate is classified as 

Mediterranean Subtropical, corresponding to an average temperature of 50 degrees Fahrenheit in the 

winter and 70 degrees Fahrenheit in the summer. Rainfall averages approximately 18 inches per year. 

2 EMCBC-DOE and The Boeing Company, Contract DE-AC03·99SF21530, Modification 108, Section C.4 "landlord 

Activities," Item (g), page 16. Document: etec_contract_sf21530_final.pdf 

'U.S. Department of Labor (DOL) DEEOIC Memorandum, "Atomics International and Energy Technology 

Engineering Center,"September 7, 2005. Document: DEEOIC_2005_Decision.pdf 

'Maps, Propulsion Field Laboratory, Nuciear Development Field Laboratory, SSFL 1956-1959. Document: 

PFL_NDFL_ 1956-1959.pdf 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 7 of 30 
Some of the site is relatively flat (Area IV), while some portions of the facility exhibit steep relief and 

rugged terrain consisting of weathered bedrock and alluvium that have been eroded primarily from the 

surrounding Chatsworth and Santa Susana formations (Areas 1-111). Several geological faults cross this 

area. A shallow groundwater system exists in the surface soils at small isolated locations. A regional 

groundwater system exists in the deeper fractured Chatsworth Formation. In some areas, groundwater 

from the Chatsworth Formation flows through fractures in the rock and emerges at the ground surface as 

seeps or springs.• 

SSFL was incepted in 1948 as an experimental nuclear and rocket engine testing facility, beginning with 

the acquisition of Area I. As more property was required to accommodate new programs and projects, the 

site expanded in a westerly direction. In 1955, NAA's Atomics International and Rocketdyne divisions 

were established. Rocketdyne functioned primarily in Areas 1-111 to develop rocket engines for the Air 

Force and the National Aeronautics and Space Administration (NASA). Atomics International functioned 

primarily in Area IV to develop nuclear technology for AEC. Based on the research and development to 

advance space-nuclear technology and later energy research conducted by DOE-ETEC, NAA Atomics 

International and Rocketdyne employees routinely rotated between NAA facilities and SSFL Areas I-IV. 

In 1966, the Liquid Metals Engineering Center (LMEC) was created on a 90-acre subset portion of SSFL's 

Area IV. By 1968, NAA had become Rockwell North American. By 1974, Rockwell International took over 

site operations as the established contractor and corporate successor to NAA. Rocketdyne and Atomics 

International continued to function as their own divisions, although worker rotation continued as various 

programs and projects were begun, advanced, or concluded. 

According to a publication by Rockwell International, LMEC's creation in 1966 was a response to 

declining development of nuclear power for space applications. The company directed efforts toward 

Liquid Metals Research and LMEC was established as a "Government Owned, Contractor 

Operated" (GOCO) facility. Its activities were focused on the development and testing of, liquid metal 

components and systems for nuclear applications, which included such devices as steam generators, 

pumps, valves, flowmeters, and other instrumentation. 

As a result of LMEC's success, DOE expanded the LMEC charter to include all DOE energy programs, 

resulting in a revision to site operations and a re-designation of LMEC to the DOE Energy Technology 

Engineering Center (ETEC) in approximately 1978.6 Facility documents show that LMEC operations had 

expanded to include facilities located in SSFL Area I, at The Bowl, potentially as early as 1974.7 Facility 

maps of ETEC operations routinely depict a diagram of Area IV, with an inset diagram of Area I, The Bowl, 

to reflect DOE-sponsored activities in conjunction with ETEC and site contractors.• 

By 1984, Atomics International was fully reorganized to become Rockwell lnternational's Energy Systems 

Group (ESG), although earlier Rockwell International documentation (c. 1970's) references ESG as its 

own division, and/or uses the terms "Atomics International" and "ESG" interchangeably. In addition, during 

this era of site operations, the contractor is frequently referred to as "Rockwell International," "Rockwell," 

"Rocketdyne," or any combination thereof. In 1996, Boeing North American (BNA) took over SSFL 

• United States Environmental Protection Agency (EPA), "SSFL Historical Site Assessment (HSA), Final Technical 

Memorandum: Area IV, Subarea HSA-5A,"pages 3-5. Document Name: 1_Final_HSA-5A_ TM_ Text_ 12_2011.pdf 

s Rockwell International, "Rocketdyne: 30 Years of American Excellence," commemorative book. Document: 

Rocketdyne_Bowl_30YearsExcellence.pdf 

' Internal Letter, Rockwell International - ESG, Re: "One-Quarter-Ton-Per-Hour Coal Hydropyro/ysis Conversion Test 

Faci/ify."September 15, 19781 Jeffs-Iacobellis. Page 2, Paragraph 5, "Proposal." California Department of Toxic 

Substances Control (DTSC) Historical Document Archive. Document: HDMSt00012824.pdf 

• ETEC Site Map, 1991. Document: Area_tV _Bowl.pdf 

DOE-ETEC Area f Operations at The Bowl, SSFL Page 8 of 30 
operations. Today, BNA is known as Boeing. The term "ETEC" is now loosely used to reference SSFL in 

its entirety throughout the history of site operations. "ETEC" is also used to reference only Area IV, or 

implied DOE-related operations. The term can also be used lo refer to the contractor, or to the original 90-

acre subset portion of Area IV. 

ETEC Operations at The Bowl / Worker Rotation 

Rotation among DOE-contractor employees between SSFL Areas I-IV has created persistent challenges 

in identifying specific employee work locations and eligibility to EEOICPA. The Area I vertical (rocket 

engine] test slands (VTS) at The Bowl provided an ideal setting for DOE-ETEC coal gasification Process 

Development Units (PDUs), which relied on rocket engine injector and propulsion technology developed 

by North American Aviation and NASA. In addition, The Bowl's test stands were located in an area of the 

site that had fallen into disuse, and the location was considered to be suitable to conduct coal gasification 

feasibility studies for DOE. Area IV did not have existing infrastructure that would meet DOE's 

requirements for such a test facility. 

Contractual agreements and facility documentation chronicles DOE-ETEC's construction, modification, 

integration, and operation of coal gasification and steam generator operations at The Bowl to support 

moHen salt, coal gasification and steam generator programs located at various Area IV locations, such as 

the Sodium Components Test Installation (SCTI), Sodium Components Test Loop (SCTL}, Sodium Pump 

Test Facility (SPTF), Building 4005 (a former Uranium Carbide Fuel Fabrication Facility that was modified 

to accommodate coal preparation processes for the POU located al The Bowl), and the DOE Kalena / 

Power-PAK reactor research programs. 

It is not uncommon to discover that DOE-contractor employees whose records document participation in 

Area I Coal Gasilication or SABER (Steam Accumulator Slowdown Evaluation Rig) operations at The 

Bowl (often reflected by Area I "lime Clock Locations" and other employment records), who also have 

documented employment at various Area IV facilities involved in coal gasification and molten salt 

research, such as those listed above.9 

In addition, it should be noted that The Bowl was not considered to be a "Restricted Area." It was 

accessible to employees ol the DOE-contractor. It has been established that workers routinely rotated 

between all areas of SSFL afler utilizing "lime Clock Locations" throughout the site, and that employees 

frequently clocked-in at one location prior to performing DOE-related job duties at another location. · 

In review of site and project history at SSFL, it should be noted that DOE operations and programs that 

were conducted at opposite ends of lhe lacillty (Area I and Area IV) required worker rotation and transport 

of materials across the site (Areas II and Ill). In addition, the company's contractual latitude to use any of 

its facilities in service to DOE provides a reasonable explanation for documented DOE waste storage and 

disposal at locations outside Area IV. Moreover, the documentation consistently supports a determination 

that SSFLArea I, The Bowl, should be considered a DOE Facility under EEOICPA and that the exclusion 

of any DOE-contractor employee based on a presumed work location is inappropriate, since covered 

employment in service to DOE programs cannot be reliably ruled out in the majority of cases. 

The following information provides references to DOE contracts for operations at The Bowl, in addition to 

sile-specilic information supportive of The Bowl's inclusion as a covered facility under EEOICPA. 

9 EEOICPA Case ID's: [Redacted) 

DOE-ETEC Area I Opera1ions al The Bowl, SSFL Page 9 of 30 
DOE· ETEC Operations at SSFL Area I· "The Bowl" 

The Bowl is located in SSFL Area I, in a concave area resembling a rock quarry. It was considered ideal 

for the first rocket engine testing facility constructed at SSFL (1948) to model Wernher von Braun's V-2 

rocket used during WWII. The V-2 is perhaps the earliest example of a rocket that utilized the molten-salt 

(liquid metal) battery concept developed by the German scientist, Georg Otto. The three vertical rocket 

engine test stands erected at The Bowl (VTS-1, VTS-2, and VTS-3) were the first rocket engine test 

stands at SSFL. 

By 1963, the VTS test stands had become outdated. Rocket engine testing at The Bowl became limited, 

as more modern test stands were constructed in other locations at SSFL. Eventually, the The Bowl's VTS 

test stands became unused until the early 1970's when Rockwell International and the Energy Research 

and Development Administration (ERDA, a DOE predecessor agency) sought a suitable location for coal 

gasification pilot test facilities. 

The assertion that DOE operations remained confined within Area IV not only conflicts with facility and 

employee records, but makes little sense when infrastructure required to accommodate various DOE 

programs is taken into consideration. Based on the original facility contract that expressly permitted the 

company to apply its discretion in utilizing the entirety of its facilities to fulfill government contracts, why 

wouldn't the contractor and DOE have used existing infrastructure? Doing so was logical, economical, 

and contractually permitted. 

Area I VTS structures at The Bowl were found to be ideal for DOE-ETEC coal gasification Process 

Development Units (PDUs) that relied on rocket engine injector and propulsion technology developed by 

North American Aviation and NASA. Conversely, Area IV did not have similar infrastructure, nor did it have 

suitable locations where the construclion of such infrastructure would be appropriate for coal gasification 

pilot plant feasibility studies. Eventually, coal gasification, steam generator, and laser research facilities for 

DOE-ETEC would result in The Bowl's allocation, in its entirety, to DOE-ETEC energy research purposes. 

Contract E(49-18)·1529: Molten Salt Coal Gasification Project 

On July 2, 1975 a letter from Rockwell-Atomics International to the Contract Services Division of ERDA 

addressed a proposed subcontract for Initial Effort for Coal Gasification Pilot Plant Design under Prime 

Contract E(49-18)-1529. 10 Additional Rockwell International / ERDA documentation (referenced in 

greater detail, below) indicates that in 1975, The Bowl Area was assigned in its entirety to Atomics 

International (which later became known as the Energy Systems Group division, or "ESG"). 

On March 28, 1976 a contract was awarded to Atomics International (ESG) by ERDA's Division of 

Procurement and Coal Conversion & Utilization (Contract No. E(49-18)-2342) for the Molten Salt Coal 

Gasification Project (MSCG), to be located at the VTS-2 Bowl Area Test Stand (SSFL Area 1). 11 

Contract E(49-18)·2342: Molten Salt Coal Gasification Project 

ERDA Contract E(49-18l-2342, Statement of Wort< (Item A, Objectives} defines project objectives 

commensurate with demonstrating the feasibility of the MSCG process for use in the environmentally 

acceptable generation of electric power. The Process Demonstration Unit (PDU) was scheduled to be 

10 Rockwell International I Atomics International letter from Donald Kniley, SSFL to C. Weirich, ERDA. July 2, 1975. 

Document: ERDA_ 7 __ 2_ 1975.pdt 

11 Contract No. E(49-18)-2342, ERDA Divisions of Procurement and Coal Conversion & Utilization to Atomics 

International, March 8, 1976. Document: Responsive_Documenls_HQ_2015_01601_F _Bowl_ERDA.pdf 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 10 of 30 
built for converting 1-Ton Per Hour (TPH) of coal to a non-polluting, low-Btu fuel to regenerate sodium 

carbonate. The 1-TPH PDU would be operated and used for research and development efforts aimed at 

optimizing the overall process and obtaining engineering and cost data for designing a full-scale 

commercial plant.12 

ERDA Contract E(49-18)-2342 Scope of Work (Item B General) specified that the Contractor would carry 

out the program in six phases that appear to fulfill statutory criteria under 42 USC § 73841 (a) and (b) to 

define DOE proprietary interest: (1) preliminary engineering; (2) detailed engineering and design; (3) 

component procurement; (4) PDU erection (construction); (5) start-up (operation); and (6) PDU operation 

and evaluation.13 

ERDA Contract E(49-18)-2342 Scope of Work (Section 8 PDll Disposition) states that the PDU was 

considered to be Government Property, appearing to fulfill both the legislative definition of DOE 

proprietary interest and the DEEOIC PM that states that evidence of DOE ownership of a building, 

structure, or premise (such as a deed or affirmative statement from DOE acknowledging ownership), or a 

contractual agreement showing that DOE had a sufficient level of use and control over the property, can 

be sufficient to establish DOE proprietary interest.'• 

Rockwell International was contractually required to provide ERDA-DOE with periodic progress reports 

based on ERDA's established contract schedule and report guidelines specified by ERDA. The contractor 

was directed to prepare reports for ERDA's Assistant Administrator for Fossil Energy; ERDA's Contracting 

Officer (CO) Representative; ERDA's Project Manager; ERDA'S Patent Office Assistance General 

Counsel for Patents; ERDA's Technical Information Center Special Assistant for Reproduction and 

Processing; ERDA's Chief of Financial Performance Section (CFPS) Finance Operations; and ERDA's 

Chief Management Analysis and Directive Branch.1• 

Contract EX-77-C-01-2518 

In 2016, CORE Advocacy provided DEEOIC with a copy of a Rockwell International Internal Letter that 

referenced DOE Contract EX-77-C-01-2518 for DOE Coal Gasification Pilot Test Facilities at The Bowl in 

SSFL Area I. The document was provided on behalf of an EEOICPA claimant whose participation in DOE 

Coal Gasilication processes has been disqualified based on The Bowl's location in Area 1. rn 

The Internal Letter proposed the expansion, modification, construction, relocation, and operation of the 

existing DOE 1/4-TPH Coal Research Pilot Plant that had operated under DOE Contract EX-77-

C-01-2518 at The Bowl since December 1975. In addttion, the letter specified that the 1975 contract had 

allocated The Bowl, in tts entirety, to Rockwell International ESG division for the advancement of the DOE 

Coal Gasification Program. 

The proposed relocation of the facility from its then-existing location at the Area I Laser Engineering Test 

Facility (LETF) to the Area I Bowl Control Center was described as an effort by ESG to, "eliminate 

operational constraints which would prevent ESG from being able to meet contract schedules." In 

"ibid., Appendix A, Statement of Work, Item A, "Objectives," Appendix page 2 / Document page 8. 

t3 Ibid., Appendix A, Scope of Work, Item B, "General," Appendix page 2 / Document page 9. 

"Ibid., Appendix A, Item B "Scope of Work," Section 8, "POU Disposition." Appendix page 5 / Document page 12. 

ts Ibid., Appendix D, "Contract Report Instructions," page 57. 

" Internal Letter, Rockwell lntemational - ESG, Re: "One-Quarter-Ton-Per-Hour Coal Hydropyrolysis Conversion Test 

Facl/ity."September 15, 1978 /Jeffs-Iacobellis.California Department of Toxic Substances Control (DTSC) Historical 

Document Archive. Document: HDMSt00012824.pdf 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 11 of 30 
addition, the letter referenced several other potentially suilable locations for the DOE facility that included 

both of the Area I Components Test Laboratories (CTL-1 and CTL·V), and the vacant rocket engine test 

stand located at The Bowl (VTS-1 ). Further, the letter described facility modifications and operations that 

would encompass the design of a 4-TPH Reactor for DOE, scheduled for completion at The Bowl in 1979. 

A need for DOE-contractor employees to operate the facility was detailed, and the letter specilied that the 

DOE-contractor employees on the lirsl shift would be allocated to "DOE Reactor Development Program 

Operations" while those on the second shift would address Hydropyrolysis Process Applications and 

Development. 

By all indications, the internal letter indicated that Rockwell International was exercising its contractual 

authority, granted by the AEC in the original facility contract, to utilize any company location at the 

contractor's discretion, in the fulfillment of DOE-related contracts; and that the contracts referenced 

specific DOE coal gasification facilities and operations located at SSFL Area I, The Bowl. 

DEEOIC determined that the document was insufficient to fulfill legislative criteria used to establish DOE 

proprietary interesls under the Act, and disqualified the employee's Area I Coal Gasification employment. 

However, new information has been obtained about DOE Contract EX-77-C-01-2518 that may provide 

DEEOIC with a sufficient basis lo reverse its decision.11 

New Information: Contract EX·77·C·01·2518 

A 1980 Rockwell International Quarterly Progress Report prepared for DOE (Contract DE· 

AC01 -78ET10328 / ET-10328-27), in accordance with the contractor's obligations lo provide DOE with 

periodic reports, clarilies that DOE Contract EX-77-C-01-2518 was considered to be a "predecessor 

contract." In addition, the progress report clarifies that DOE changed its contractual numbering scheme 

for the DOE Coal Hydrogasiflcation Program at SSFL. ta 

The Quarterly Progress Report outlines the objectives and scope of the advance and development of coal 

gasification facilities lor DOE, including the design, construction and operation of a 3/4-TPH coal-feed 

rate integrated process development unit (IPDU) at the "ESG Energy Bowl."1

9 

The Quarterly Progress Report describes a scope of work involving an integrated combination of design, 

construction, and operation. It clarifies that, while designing and beginning construclion of the IPDU at 

The Bowl, some testing had already been carried out under the predecessor contract (EX-77-01-2518). A 

diagram outlines the program schedule for the facility's design, advanced procurement, construction, 

design and fabrication of reactor trains, preparation of systems operation, and tesling. Additional 

information is provided in the Summary of Progress, which describes the construction and integration of 

the facility, and implementation of a preliminary data process stream regarding air, water, ground 

contamination, and the production of benzene, toluene and xylene. A photo (p. 18) of the facility shows its 

integration onto a v.ertical rocket engine test stand (VTS) located at SSFL Area I, The Bowl. 01 interest 

are the former liquid oxygen tank (LOX) once used for rocket engine testing, and additional Bowl Area 

vertical rocket engine test stands visible in the background. 

11 Case ID: [Redacted]. Roci<well Employee / Area I (The Bowl) Coal Gaslllcalion, SABER, APTF / Area IV (SCTI) 

Molten Salt Testing 

1a Rockwell International ESG for DOE, Quarterly Progress Report, •eoa.l Hydrogas/1/cation Process Development,• 

lorthe period October 1, 1980 to December 31, 1980. DOE Contract No. DE-AC01-78ET10328. 

Document: RockwelU:SG_ 1981.pdl • See Page 9. 

19 Ibid., Document page 6, Section 3.0 - "Description of Technical Progress." 

DOE-ETEC Area I Operations at The Bow1, SSFL Page 120130 
REACTOR 

BAY 

2026 FT. ELEV. 

ELEV~.TOR EOUIP. 

ROOM 

COAL ?REP. 

CYCLO:iE 
New Information: Contract EX-77-C-01-2518 (continued) 

According to a 1978 report authored by Bechtel National, Inc., the Rocketdyne coal gasification program 

was sponsored by DOE under Contract EX-77-C-01-2518. 20 The Rocketdyne tests were conducted in an 

"entrained-down flow tubular reactor system" designed to feed coal at up to 1 /4-TPH, which describes the 

1/4-TPH coal hydropyrolysis facility integrated onto a VTS structure at The Bowl. 

A 1979 report authored by Rockwell International ESG references studies in coal, peat, and flash 

hydropyrolysis that utilized "rocket engine techniques" to achieve rapid mixing-reaction at optimum 

temperature and residence time, under DOE Contract EX-77-C-01-2518. In addttion, the document 

references subsequent reactor development programs under DOE Contract ET-78-C-01-3125 for the 4-

TPH coal hydrogasification reactor system at the ETEC Bowl Area.21 

Based on numerous references to DOE Contract EX-77-C-01-2518 by DOE, its predecessor agencies, 

and tts contractors that support the contract's scope of work as related to DOE operations and coal 

gasification facilities at The Bowl, it is reasonable to expect that DEEOIC will carefully consider and 

compare the totality of information provided. There appears to be a basis for DEEOIC to reverse its 

determination that DOE Contract EX-77-C-01-2518 was insufficient to establish DOE proprietary interests 

in coal gasification processes at The Bowl. 

Rockwell International Publication, c. 1970's 

A publication by Rockwell International (c. 1970's) provides information about the company's areas of 

research and development at various locations throughout the U.S. The company states that, at the time 

of the document's publication (under contract with DOE), the company had advanced the development of 

two processes for the extraction of clean-burning gas from coal at SSFL. A description of the processes 

was provided.22 

One of the processes involved a molten salt mixture at a high temperature. Based on the description of 

the process, the timing of the publication, and other related documentation, it is reasonable to conclude 

that Rockwell International was describing the 1-TPH POU that began in 1976 under DOE Contract 

E(49-18)-2342, which provides a detailed description of the Molten Salt Coal Gasification (MSCG) Project 

at The Bowl. 

The second DOE-sponsored process referenced the Flash Hydropyrolysis POU, and stated that the 

company had relied on technology developed by NAA for rocket engine injectors and NASA propulsion 

concepts, in order to power a 100-TPD (Ton Per Day) advanced reactor system. Based on additional 

documentation cited herein, it is reasonable to conclude that Rockwell lnternational's publication was 

referring to the 4-TPH Reactor slated for completion in 1979, at the VTS-3 rocket engine test stand 

structure.23 A photograph of a rocket engine test fire at the VTS-3 test stand (The Bowl) was provided by 

Rockwell International, alongside a diagram of the coal gasification concept. (Please see following page). 

20 Bechtel National, Inc., "Reactor Performance During Rapid-Rate HydrogasifiC8.tion of Subbituminous Coal, 'by M. 

Epstein, T.P. Chen, and M.A. Ghaly. Document: 23_3_Miami Beach_09-78_0168.pdf 

21 Rockwell International, Energy Systems Group (ESG), "Experimental Investigation of Peat Hydrogasification, 'by 

F.D. Ranier, L.P. Combs, and A.Y. Falk. Document: Vol-24_3·0005.pdl 

22 Rockwell International, Energy Systems Group, Company Publication, c. 1970's. 

Document: Energy_Systems_Group.pdf 

23 Internal Letter, Rockwell International - ESG, Re: "One-Quarter-Ton-Per-Hour Coal Hydropyro/ysis Conversion Test 

Faci/ity.'September 15, 1978 I Jeffs-Iacobellis. California Department of Toxic Substances Control (DTSC) Historical 

Document Archive. Document: HDMSt00012824.pdf 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 14 of 30 
The second process. Oash hydropyrolysis. uses 

Rockwell rocket engine-injector technology for 

extremely rapid thorough mixing of pulverized coal 

and 2000°F hydrogen. The product is either a high 

Btu. pipeline quality gas or a combination of gas and 

liquid fuel. depending on process variables. A 100-

ton-per-day advanced hydrogasification reactor 

system designed by the division is to be built at the 

field laboratory for process testing. 

Advancement of the process toward full 

commercialization is the objective of a working 

agreement between Rockwell International and 

Cities Service Company which has long been active 

in laboratory development of the technology. 

Flue Gas Desulrurization 

A dry desulfurization and particulate removal 

system is Rockwell's solution for air-polluting 

emissions from plants burning coal or oil that 

contain sulfur. 

Two commercial system applications of the 

process are under construction at U.S. coal-burning 

power plants. A group of five utilities has contracted 

for the installation of the innovative dry-scrubber 

system at the Coyote Station near Beulah. North 

Dakota. Rockwell and the Air Pollution Control 

Division of Wheelabrator-Frye. Inc. are supplying 

the system as a joint venture project. Rockwell will 

supply the scrubber system for sulfur dioxide 

removal from the 410 megawatt plant, including 

Stork-Bowen spray dryers. and Wheelabrator-Frye 

provides fabric filter collectors. A similar, smaller 

system is being installed on an industrial boiler in 

Maryland for the Celanese Corporation. 

Rockwell's dry nue gas desulfurization system 

has also been selected for demonstration in an 

Environmental Protection Agency project. In this 

project. the absorbent material is regenerated and 

recycled. minimizing solid or liquid waste disposal 

requirements. EPA has authorized the Empire State 

Electric Energy Research Corporation (ESEERCO ) 

a group of eight New York utilities. to install the 

Rockwell system on Niagara Mohawk's Huntley 

Station near Buffalo. New York. In addition to EP,'\ 

and ESEERCO. support for this project is expected 

from the New York State Energy Research and 

Development Administration and the Electric Power 

Research Institute. 

Environmental Monitoring and Services Center 

An important part .of the Division. the Center is 

active worldwide in every phase of environmental 

Rocket engine technology appliPd to advanced coal gasification and liquefaction prcce-;,~ ; 
Mid-1980's Commemorative Book by RI: "Rocketdyne: 30 Years of American Excellence" 

A commemorative publication by Rockwell International described coal gasification operations under 

contract with DOE, indicating that the company and DOE had commenced two energy development 

projects involving the exlraction of clean-burning gas and liquid hydrocarbons from coal, before 1973. 

Again, the company featured a description of NAA rocket injector concepts and NASA propulsion 

technology to describe coal gasification operations at former Bowl Area rocket engine test stands.24 

1990: RI-DOE Action Description Memorandum: SABER Operations at The Bowl 

In 1990, Rockwell lnternational-ESG issued an Action Description Memorandum to address a new project 

for ETEC at The Bowl: the Steam Accumulator Slowdown Evaluation Rig (SABER), a Large-Scale Steam 

Valve Test Facility (LSSVT). There are indications that the facility was used to support DOE's Kalena / 

Power-PAK reactor research programs and other Area IV operations/lacilities. 

The SABER's purpose was to conduct large-scale steam valve tests to demonstrate performance. The 

Action Memo resulted from an agreement with DOE for ETEC to provide steam-valve testing services. It 

was classilied as a development project. According to the Memo, a search had been conducted 

throughout SSFL for a test facility that could supply the steam flow and steam quality conditions required 

for the valve tests. 

The search Identified that the VTS-3 test stand at The Bowl would be the only existing site that 

could meet the required conditions. In addition, Rockwell lnternatlonal stated that the test system 

design, procurement, construction, and management had been carried out by ETEC and that The 

Bowl was located in Area I on POE optioned !and.25 

The Action Memo provides a detailed diagram of SSFL that shows ETEC facilities located at Area IV and 

at The Bowl in Area I. An enlarged diagram of The Bowl is provided, showing its facilities and structures 

used for DOE-ETEC operations. The Action Memo describes Rockwell lnternational's site permtt for the 

possession and use of radioisotopes covering the use of the gamma densitometers in the LSSVT. An 

"Authorization for Use of Radioactive Materials or Radiation Producing Devices" (Authorization Number 

152) was issued. DOE's documented use of radioisotopes or radiation-generating equipment outside Area 

IV should be noted. 

In addition to the VTS-3 test stand, the SABER utilized several of The Bowl's existing buildings and 

structures. The Memo acknowledges that VTS-3 was formerly used as a rocket engine testing facility and 

a coal gasification testing facility that had been allocated to a DOE contract with the Morgantown Energy 

Oflice for use in a coal liquefaction process development project. 

24 Rockwell International, "Rocketdyne: 30 Years of American Excellence, "commemorative book. Document: 

,s Department of Toxic Substances Control (DTSC) Historical Document Archive, "Steam Accumulator 8/owdown 

Evaluation Rig Large Scale Steam Valve Test Action Description Memorandum," Rockwell International, 1990. 

Document: HDMSP00019780.pdf 

Document Citations: 

1. ETEC letter from F. W. Poucher to A. J. Adduci of DOE-SAN," WFO Checklist and Revision 8 to Field Work 

Proposal ID #6951 (E-88-4), Large Scafe Steam Valve Test', 88ETEC-DRF-295, December 21, 1988. 

2. "Geotechnicaf Investigation, ETEC Kafena Cycle Plant, Rockwell International, Santa Susana, California', Gorlan 

and Associates , Soils Foundation Engineers , dated June 24, 1988 . 

3. VCAPCD letter to Rockwell, "Re :Authority to construct #0271-110'; 89ETEC -DRF-1435," July 19, 1989. 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 16 of 30 
1991 DOE Tiger Team Assessment of ETEC 

A 1991 map of "ETEC Operations" published by the DOE depicts ETEC facilities at SSFL, and shows that 

Area IV and The Bowl at Area I were considered to be ETEC. The map includes a diagram of Area IV with 

an inset diagram of The Bowl in Area I. The map specifies that these locations are specific to ETEC, and 

that the facilities listed as "Govt." were considered to be DOE Facilities.2' (See map, p. 18). 

1991 Report of Telephone Conversation· Area I SABER/ APTF 

On October 3, 1991 Rockwell International generated a Report of Telephone Conversation wherein 

emissions from the SABER and the Advanced Propulsion Test Facility (APTF) were addressed, along with 

related excursions at the Sodium Components Test Facility (SCTI) located in Area IV. 

There are indications that the SABER, Advanced Propulsion Test Facility (APTF, Area I) and the SCTI 

(Area IV) operations were supportive to one another to meet various contract schedules in research and 

development, and that the excess emissions posed continued problems for the company in compliance 

with existing regulato,y standards. Based on the internal report and distribution list that included SSFL 

departments in Area I and Area IV, and the recipients included in the report, it is reasonable to conclude 

that ETEC operations in Area I and Area IV were intimately intertwined based on a need to meet specified 

contractual obligations to DOE.27 

1992 ETEC Environmental Protection Implementation Plan (EPIP), Revision C 

In 1992, Rockwell International wrote to DOE-ETEC in reply to ETEC correspondence (92ETECDRF-01940), the "ETEC Environmental Protection Implementation Plan (EPIP), Rev. C," to provide its 

annual update to the EPIP, pursuant to DOE Order, DOE 5400.1. Revision C covered the EPIP from 

November, 1992 to November, 1993.28 

DOE Order Number DOE 5400.1 (Chg.1, 6/29/90), "General Environmental Protection Program," 

established environmental protection and restoration program requirements, authorities, and 

responsibilities to ensure that DOE operations were in compliance with applicable Federal, state, and 

local environmental protection laws and regulations, Executive Orders, and internal department policies. 

Chapter Ill of DOE 5400.1 required that each field organization prepare a plan for implementing the 

requirements of the Order by no later than November, 1989 and update the plan annually. ETEC provided 

the EPIP for the DOE Operations at SSFL. Section 1.5.5, "Facility Programs, SCTI Programs, General 

Programs / Advanced Planning" states that site departments perform Program Management activities 

related to the Development & Testing, and Environmental Restoration activities required by DOE. The 

scope of responsibilities included the Liquid Metal Research (LMR) programs and generally any on-site 

tests, depending on the customer and the type of test. Environmental restoration activities at Area IV and 

The Bowl in Area I were scheduled in accordance with EPIP, as required by DOE. (See Map, p. 19). 

,. U.S. DOE Office of Environment, Safety and Health, "Tiger Team Assessment, Energy Technology Engineering 

Center,' 1991. ETEC Site Map - Area IV/ Area I, The Bowl, page 28. 

Document: DOE_EH-0175_ES&H_ Tiger_ Team_Assessment_of_ETEC.pdf 

"Rockwell International, Environmental Protection, "Report of Telephone Conversation,• Bill Flynn, Air Quality 

Engineer, Ventura County Air Pollution Control District, October 3, 1991. BNA Document #BNA00293309, California 

Department of Toxic Substances Control (DTSC) Historical Document Archive, Document: HDMSe00425825.pdf 

"Rockwell International, ETEC Internal Letter to Robert LeChevalier, DOE-ETEC. Refer to: 92ETEC-DRF-1940. 

Subject: ETEC Environmental Protection Implementation Plan (EPIP), Rev. C. November 18, 1992. 

Please see PDF pages 62 {Appendix I, Figure 1-A, document page 1-58) and PDF page 65 (GEN-AT-022, Rev. C, 

Appendix II, document page 1/-61). Boeing North American (BNA) Document#: BNA01261268. California Department 

of Toxic Substances Control (DTSC) Historical Document Archive, Document: HDMSe00413923.pdf 

DOE-ETEC Area t Operations at The Bowl, SSFL Page 17 of 30 
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The EPIP describes ETEC's site-wide responsibilities that included SSFL Areas I, II, Ill and IV and 

ETEC's utilization of Rockwell-Rocketdyne's administrative functions, services, and Environment, Health 

and Safety Department. In addition, ETEC represented the Division in all matters involving regulatory 

agencies, and ensured compliance with regulations that included DOE Orders. 

The EPIP states that ETEC's SSFL operations provided management and operation of faciltties, 

maintained the required permits and pollution abatement equipment, assisted Rockwell-Rocketdyne's 

emergency response personnel in remedial actions involving spills and emergency response actions in 

any area of SSFL, provided appropriate documentation under the National Environmental Policy Act 

(NEPA) to DOE (as required by DOE Order), provided management of hazardous waste during the 

storage retention period, and worked under the oversight of DOE. 

It should be noted that the EPIP contains no reference or provision to suggest that ETEC operations were 

restricted to, or confined within Area IV. Rather, ETEC's active role on a site-wide basis, in a variety of 

DOE-sponsored activities, is described in detail.'" 

1992: Boeing North American's (BNA) Description of Operations at The Bowl, SSFL Area I 

A 1992 document generated by Boeing North American (BNA) describes The Bowl Test Area as the first 

rocket engine test facillty constructed at SSFL, located in the southern one-third of Area I, and comprised 

of three rocket test stands; the Bowl Retention Pond; the Bowl Skim Pond; and a control center. In 

addition, the document states, "Two inactive coal gasification facilities remaining from circa 1970's DOE 

programs (that] are located (one each) on a test stand and at the control center," and describes 

supportive operations for coal gasification at Building 4005, located in Area IV.3° 31 

1995: BNA Document· "29 DOE Buildings" 

An undated document generated by BoeiQg North American (BNA01837452) and titled, "29 DOE 

Buildings, Smith Briefing I 30 bldgs on IL 's from ETEC, • depicts ETEC-DOE buildings at SSFL and 

includes The Bowl VTS Test Stands and Steam Generator facilities. It should be noted that the document 

was generated by Boeing.32 

2005: Pratt & Whitney Rocketdyne/DOE Advanced Single Stage Gasifier Development Program 

In 2005, Pratt & Whitney Rocketdyne presented at the Gasification Technologies Conference. With a 

PowerPoint presentation, the company detailed the "Pratt & Whitney Rocketdyne / DOE Advanced Single 

Stage Gasifier Development Program." The presentation was prepared with the support of DOE, under 

Contract Award No. DE-FC26-04NT42237. 

The PowerPoint presentation features photos of the Rockwell International coal gasification PDU systems 

that had been integrated onto VTS test stands at The Bowl. As Pratt & Whitney Rocketdyne is considered 

to be a corporate successor to NAA, it assumed operations at Canoga Facility in 2005 and continued 

29 Ibid. PDF page 27, document page 20, Section 1.5.3 General Programs & Advanced Planning 

30 Untitled, Boeing North American (BNA) Document#: BNA040606123. "Bowl Area: Bowl Retention Pond, Bowl 

Skim Pond, and Bowl Test Stands," November, 1992. California Department of Toxic Substances Control (DTSC) 

Historical Document Archive, Document: HDMSp01739799.pdf 

" California Department of Toxic Substances Control (DTSC) Historical Document Archive, Boeing Document#: 

BNA01375901. See PDF pages 3 (Bowl, Area I) and 28 (Building 4005, Area IV). Document: HDMSe00399178.pdf 

32 Boeing North American (BNA) Document#: BNA01837452. California Department of Toxic Substances Control 

(DTSC) Historical Document Archive. Document: HDMSE00375150.pdf 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 20 of 30 
contractor operations at DeSoto Facility and SSFL (Areas I-IV). According to Boeing, workers rotated 

between Canoga, DeSoto, and potentially SSFL Area IV while employed by Pratt & Whitney-Rocketdyne, 

but did not necessarily have any change to job codes or other administrative records that would reliably 

document worker location. DEEOIC may consider a need to further evaluate DOE interests at Canoga 

and DeSoto Facilities, after DOE operations and interests were presumably discontinued.33 

Beryllium, Tritium, and Radlonuclides at SSFL Area I 

Tritium, beryllium, and radionuclide contamination has been discovered in Area I, further calling into 

question DOE's claims of Area IV exclusivity. In 1964, NAA conducted a study of beryllium handling, 

operations, and potential contamination at Happy Valley (Area I). The study was to evaluate personnel 

exposure to beryllium and the extent of residual contamination in the work area. The study revealed that 

the maximum average integrated personnel exposure was greater than 96% of the allowable exposure, 

and that residual beryllium contamination exceeded the recommended level in several locations. 

The study also concluded that the calculated exposure was inaccurate to an unknown degree because 

the amount of beryllium in some of the samples exceeded the upper limits of the analytical techniques 

used for measuring. Thus, the study concluded that the estimated exposure level of "greater than 96% of 

the allowable exposure" was likely a grave underestimation. The study observed that up to 1964, airborne 

dust generated by beryllium operations had not been controlled, and employees had never been provided 

with respiratory protection. 34 as 36 31 

In 1983, the Department of Industrial Relations Division of Occupational Safety and Health Radiation 

Health Untt contacted Rockwell lnternational-Rocketdyne regarding an incident investigation under 

California Radioactive Material License Number 0273-70.38 

The division indicated that on August 17, 1983 an investigation was conducted relative to the company's 

unauthorized possession of tritium in an amount and form that had not been authorized under the current 

license. The investigation and environmental survey to determine the scope of tritium contamination 

revealed that, beginning in 1979, unauthorized amounts of tritium gas in amounts that exceed 1,000 

microcuries had been received periodically at locations in Area I that included CTL-111 and the LETF, both 

of which were part of DOE-ETEC operations in 1979. 

33 Pratt & Whitney - Rocketdyne: "DOE Advanced Single Stage Gasifier Development Program, "October 12, 2005. 

Document: PRW_SSG.pdt 

34 Internal Letter, NM: Study of Hybrid Motor Operations, Happy Valley, SSFL. Boeing North American (BNA) 

Document #162895. Cal~ornia Department of Toxic Substances Control (DTSC), Document: HDMSe00420866.pdf 

" Rockwell International, 1981. "Be Tanks," documenting Beryllium drainage offsite, and contamination to Area I 

locations. Boeing North American (BNA) Document #BNA02770421. California Department of Toxic Substances 

Control (DTSC) Historical Document Archives. Document: HDMSe00423553.pdf 

36 NM, Industrial Hygiene & Safety. September 1, 1966; Propellant Engineering Laboratory, Area I. Rockwell 

International Document #SS-SS72-00531. California Department of Toxic Substances Control (DTSC) Historical 

Document Archives. Document: HDMSP00028757.pdf 

37 Internal Letter, Rocketdyne, Re: Beryllium Contamination at Happy Valley. 919165. Rockwell International Document 

#RI-SS72-00504. California Department of Toxic Substances Control (DTSC) Historical Document Archives. 

Document: HDMSP00028751.pdf 

" California Department of Industrial Relations Division of Occupational Safety and Health, Radiation Health Unit to 

Rockwell International, August 26, 1983. Boeing North American (BNA) Document #BNA02657088. California 

Department of Toxic Substances Control (DTSC) Historical Document Archive. Document: HDMSe410222.pdf 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 21 of 30 
SSFL Area I Bowl Energy Center: Added I Removed from Site Exposure Matrix (SEM) 

The DOE-ETEC Bowl Energy Center Coal Gasification Facility was added to the SEM as a "covered 

facility" under EEOICPA. Presumably, its addition was based on the knowledge that coal gasification 

operations are known DOE processes, and the premise that all DOE operations at SSFL were confined to 

Area IV. 

It has been established that coal gasification and its associated processes are considered to be DOE 

operations at other Rockwell International facilities (i.e. Hanford and Rocky Flats). It is likely that The Bowl 

was assumed to have been located in Area IV, based on the current understanding that DOE operations 

were confined to that area ol the site.a• 

In 2016, The Bowl was removed from the SEM. Upon inquiry, the SEM Public Administrator indicated that 

The Bowl's removal from the SEM was based on its location in Area 1.40 

It appears that a clear action is called for, based on documentation establishing that coal gasification and 

its associated processes are DOE operations. In addition, DOE ownership, control, and proprietary 

interests in the faciltties at The Bowl are well documented. It would be reasonable to expect that the next 

course of action would be to accept that DOE conducted operations outside of Area IV, and to classify 

Area I, The Bowl, as a DOE Facility under EEOICPA, accordingly. 

Conclusion 

CORE Advocacy supports EEOICPA's administration based on accurate characterizations of site and 

worker history as documented by DOE, its predecessor agencies, and its contractors. EEOICPA's ability 

to function should never be hampered by incomplete, erroneous, or summary information that fails to 

acknowledge the scope of DOE operations or processes that may have put employees at risk. 

DOE-ETEC operations at SSFL Area I, The Bowl, are reflected in contractual agreements and technical 

documents that provide robust and descriptive accounts of facilities that were constructed, modified, 

integrated, operated and remediated by and on behalf of DOE. It appears that, based on the 

documentation provided, SSFL Area I The Bowl fulfills criteria under 42 USC § 73841 (a) and (b). 

Documentation shows that DOE-contractor employees routinely participated in DOE-ETEC operations at 

Area I (The Bowl) and Area IV, in service to DOE-sponsored programs, and that the employees fulfill 

eligibility criteria under EEOICPA. Based on the 2005 eligibility decision, any employee of NAA, its 

divisions or corporate successors that can establish employment by the company at a location where 

DOE conducted operations may be potentially eligible for EEOICPA. 

CORE Advocacy respectfully requests that ETEC operations at SSFL Area I, The Bowl, be acknowledged 

and that SSFL Area I, The Bowl (also known as The Bowl Energy Center or ESG Bowl), be considered a 

DOE Facility and "covered area" under EEOICPA. 

CORE Advocacy respectfully requests a detailed response from DEEOIC and DOE. Should DEEOIC and 

DOE determine that contractual agreements documenting DOE operations and interests in coal 

gasification at SSFL Area I, The Bowl do not sufficiently establish DOE proprietary interests, CORE 

Advocacy respectfully requests a well-reasoned narrative that explains exactly how the contractual 

agreements, and other information provided, are deficient. 

39 ETEC Bowl Energy Center - Site Exposure Matrix. Document: SEM_BowlArea.pdf 

«> ETEC Bowl Energy Center - Site Exposure Matrix. Document: SSFL_SEM_Bowl_Removal.pdf 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 22of 30 
It is a privilege to submit this information on behalf of SSFL personnel and EEOICPA claimants at large. In 

addition, please note that this document contains new and relevant information likely to have bearing on 

EEOICPA Case ID [Redacted] ; a DOE~ontractor employee and documented participant in DOE 

operations at The Bowl who has been summarily disqualified from EEOICPA. 

Based on the information herein, the employee appears to have sufficiently provided ample evidence of 

employment by the company at a location where DOE operated. It is my conviction that this employee, 

and his coworkers whose job duties for DOE involved coal gasification processes at The Bowl, deserves 

inclusion to EEOICPA based on employment for an established DOE contractor and involvement in 

established DOE processes, at a location that fulfills criteria under EEOICPA to be considered a DOE 

Facility and a "covered area." 

CORE Advocacy has provided a comprehensive bibliography and a link to download cited documents in 

their entirety, from a secure folder at Dropbox, at the end of this document. In addition, the roHowing 

supplemental information pertains to issues of potential and relevant conflicting_interests that are likely to 

have created difficulty in identifying DOE operations at SSFL, verifying eligibility among DOE-contractor 

employees, and ensuring that verified eligible claimants receive relevant dose reconstruction outcomes. 

The agencies that are tasked with administration of EEOICPA should be made aware of any potential 

issues, even those that may exist outside of EEOICPA legis,ation, that may compromise the claims 

process for SSFL workers so that the agencies can respond accordingly, 

It is CORE Advocacy's privilege to provide information that may assist DEEOIC and DOE in ensuring that 

EEOICPA Is administered fairly and effectively for the workers of Santa Susana Field Laboratory (SSFL) 

and its associated facililies. 

Sincerely, 

~ D'Lanie Blaze 

CORE Advocacy for Nuclear & Aerospace Workers 

DOE-ETEC Area I Operations al The Bowl, SSFL Page23of 30 
Additional Information: Conflicting Interests/ EEOICPA Ellglblllty Issues 

CORE Advocacy's priority is to ensure that EEOICPA functions as intended for SSFL employees; claim 

adjudication should be based on factual information regarding site history and employee records. 

However, there are compelling indications that conflicting interests outside of EEOICPA have hampered 

the claims process for an unknown number of SSFL EEOICPA claimants. The problems appear to be 

rooted in summary information provided by the contractor at various phases of the claims process, from 

initial Employment Verification requests to the information included in the SSFL Site Profile used for 

radiation dose reconstruction. 

It should be noted that DOE and Boeing remain engaged in a decades-long, controversial environmental 

cleanup of SSFL. Both stand to benefit by downplaying the scope of DOE operations and activities at 

SSFL that may have resulted in environmental contamination, worker exposure, and potential health risks 

to employees and surrounding communities. By diminishing the perception of DOE activities and worker 

exposure at the site, environmental cleanup obligations stand to be significantly lessened. 

There are growing indications that DEEOIC's eligibility decision and the dose reconstruction process for 

SSFL workers have been undermined, effectively reducing the number of workers found to be eligible for 

consideration and the number of approved claims under EEOICPA, thus supporting a perception of 

minimal DOE activities or operations that may have posed health risks to workers of the site. 

DEEOIC's Ellglbllity Decision and Dose Reconstruction for SSFL Workers 

In 2005, DEEOIC indicated that it had been DOE and Boeing's "goal" to limit EEOICPA eligibility to a 

smaller subset of NAAAtomics International employees of the 90-acre subset portion of Area IV known as 

ETEC. DOE and Boeing's effort to enforce a restrictive eligibility policy resulted in a three-year 

"disagreement" with DEEOIC, resulting in all claims associated with SSFL (and its affiliated sites) being 

placed into ''pending" status. Between 2002-2005, a number of sick SSFL workers died while their 

EEOICPA claims were effectively stalled. 

A 2015 FOIA Request revealed that between 2002-2005, DEEOIC attempted productive dialogue with 

DOE and Boeing in an effort to resolve conflict about which workers should be eligible for EEOICPA. 

Likely unaware of any potential for outside conflicting interests that may influence the quality or 

completeness of information ·provided by DOE or its contractor, DEEOIC permitted Boeing to weigh in on 

the creation of eligibility policy during the deliberative process and to provide guidance on the adjudication 

and outcome of 38 open EEOICPA claims in various phases of adjudication. In addition, the contractor 

was permitted to define the types of information it would provide to DEEOIC in response to Employment 

Verification requests used to establish SSFL worker eligibility to EEOICPA.41 

On September 7, 2005 DEEOIC found that the entirety of Area IV would be considered the "covered area'' 

and that any employee of NAA, its divisions (Atomics International or Rocketdyne), or corporate 

successors that could provide documentation of employment by the company at a location where DOE 

operated could be potentially eligible for EEOICPA. DEEOIC clarified that, based on the original facility 

contract and worker rotation, it may not be possible to make a distinction between which NAA employees 

had performed DOE-related job duties in Area IV. 

As part of the Employment Verification process, DOE and Boeing were directed to provide DEEOIC with 

factual information showing actual employee work locations at SSFL, to assist DEEOIC in verifying 

worker presence in Area IV and establishing eligibility to EEOICPA. DEEOIC further clarified that one 

effect of the eligibility decision would be that EEOICPA would be made available to more workers than 

previously anticipated. 

" FOIA 790488. Document: FOIA_790488.pdf 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 24 of 30 
Since 2014, it has been established that Boeing's Employment Verification summaries have never been 

sufficient to reliably or accurately establish eligibility based on Area IV employment, because the 

summaries do not provide factual information depicting employee work locations at SSFL. Rather, 

Boeing's summaries routinely obscure covered employment that meets DEEOIC's 2005 eligibility 

criteria. In many cases, years or decades of eligible employment is disqualified in error, based on the 

Boeing summary. 

As a result of relying on Boeing's summaries to make eligibility determinations, an unknown number of 

SSFL workers have been systematically disqualified from EEOICPA in error. It is not uncommon to 

discover that, based on thorough review of employment records, the employee actually meets eligibility 

criteria and should have been considered eligible to apply for EEOICPA. In addition, there are growing 

indications that the summaries may have been constructed specifically to identify Q!l)y Atomics 

International ETEC employees that DOE and Boeing originally intended to be eligible for EEOICPA, while 

effectively obscuring covered employment among many of the additional employees that DEEOIC 

included in the 2005 eligibility decision. 

While some workers are disqualified from EEOICPA in totality, others with readily-identifiable covered 

employment depicted in the summaries (primarily Atomics International ETEC employees) proceed 

through the adjudication process to dose reconstruction. However, in numerous instances, many of the 

eligible workers are also discovered to have years (or decades) of additional covered employment that 

have been effectively obscured by the summary, and disqualified from EEOICPA. Thus, of those workers 

who are determined to be eligible for EEOICPA, many of the eligibility determinations are incomplete. 

In a growing number of instances, claims are adjudicated in their entirety based on an incomplete 

depiction of covered employment, and sent to dose reconstruction with only a partial characterization of 

radiation exposure history. As a result, the perception of the employee's exposure may be dramatically 

diminished and the probability outcome may be substantially underestimated, since not all covered 

employment or radiation exposure may be evaluated. 

The deficiencies in the Employment Verification process appear to have significantly reduced the number 

of eligible employees that are considered under EEOICPA, in addition to compromising the quality of 

claim adjudication and dose reconstruction, resulting in fewer accepted claims. In addition, there are 

suggestions that information provided by the contractor for inclusion to the SSFL Site Profile was grossly 

deficient, resulting in a further compromise to the integrity of dose reconstruction. 

The SSFL Stte Profile appears to have been based predominantly on summary data authored by Boeing 

and its contractors after 1996. In 2016, CORE Advocacy compared the SSFL Site Profile to the U.S. 

Environmental Protection Agency's (EPA) 2009 Historical Site Assessment (HSA) and Area IV 

Radiological Characterization Site (Site Study). The HSA and Site Study were based on EPA's analysis of 

1.4 million historical facility documents that had been provided to the EPA by DOE and Boeing in 

response to several formal information requests. Several conflicts between the SSFL Site Profile and the 

2009 HSA were noted. 

CORE Advocacy identified what appears to be 50 additional Area IV facilities, several of which were 

considered to be major sources of radioactivity generation at the site, that had been excluded from the 

SSFL Stte Profile. In addition, all corresponding worker and environmental monitoring data associated 

with facility operation, and incident reports documenting potential releases and worker exposure, were 

excluded. On review of the SSFL Sile Profile, it seems that only limited information was provided, which 

pertained to the most significant buildings or operations at SSFL. It appears that all support facilities and 

lesser-known operations associated with DOE's extensive nuclear and energy research programs at 

SSFL were excluded. 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 25 of 30 
In some instances, information in the SSFL Site Profile clearly conflicted with information provided to EPA 

by DOE and Boeing. For example, the SSFL Site Profile contains the contractor's assertion that no 

radioactive waste was ever incinerated at SSFL. In contrast, Boeing provided EPA with substantive 

documentation pertaining to Area IV Building 4664 (excluded from the SSFL Site Profile}, which 

functioned for 25 years as a low-level radioactive waste incineration facility. According to EPA, this 

location was a main source of airborne radioactivity at the site. It is reasonable to conclude that NIOSH 

would consider this operation to be significant to the application of dose reconstruction, and its exclusion 

from the SSFL Site Profile may have bearing on the quality of dose reconstruction for SSFL workers. It 

was one of approximately 50 locations that were not included in the SSFL Site Profile. 

The 2009 HSA and Site Study were submitted to NIOSH for evaluation and potential inclusion to the 

SSFL Site Prolile in August, 2016. 

CORE Advocacy Recommendations: Historical Facility Documentation 

As EEOICPA is a non-adversarial program, claimants deserve decisions that are based on an accurate 

characterization of site and worker history. Conflicting interests that may exist outside of EEOICPA should 

never be permitted to derail or compromise a worker's ability to rely on due process under the Act. 

Agencies tasked with EEOICPA's administration should remain aware of the potential for conflicting 

interests to influence information requests and claim adjudication, and take reasonable precautions to 

ensure accuracy and completeness of information that is used or reviewed during the claims process. 

It is reasonable that DEEOIC would need to occasionally rely on information provided by DOE and 

Boeing. However, based on the consistency of established deficiencies in summary data provided by the 

contractor, CORE Advocacy respectfully recommends consideration of the following: 

• According to the contractor, Boeing maintains detailed employee databases dating back to the 1940's; 

is in possession of at least 1.4 million historical facility documents that were provided to EPA to conduct 

the 2009 HSA and Site Study; and Boeing is legally and contractually obligated to provide the 

information to DOE and DEEOIC in support of the FOIA, Privacy Act, and the EEOICPA. There is likely 

no need to create summarized information, when the original documentation is available . 

• II summary information is provided, any historical records used to create the summary should also be 

provided, in the interest of accuracy and completeness. This should include any "coded" records, and 

any prospective "key'' required to decode the records. It should be noted that records and codes 

generated pre-1996 were neither created by, nor considered proprietary to Boeing. 

• When a historical record challenges summary information provided by the contractor, particularly when 

the historical record benefits the claimant, the authentic historical record should take precedent over 

summarized data. 

• Whenever possible, historical records authored by DOE / Boeing predecessors (pre-1996) should be 

evaluated and considered over any newly-generated summary data. 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 26 of 30 
Bibliography 

PDF Documents can be downloaded as a .zip file, by oopvini:i and paslino this link to your browser: 

[Redacted) 

; 

Problems downloading? Adlsl< will be provided in your preferred fonnat. Just make contact at: 

speak@COREAdyocacy.org / 818.835.1431 - D'Lanie Blaze, CORE Advocacy.org 

1. Sanford Cohen & Associates (SC&A), "Review of the NIOSH Site Profile for the Santa Susana Field Laboratory,• 

Contract No. 200-2004-03805, Task Order 1: Draft Report, SCA-TR-TASK1-0027. 

See pages 12 & 48. 

File Name: sca-ssflsp-rOa.pdl 

2. u.s; Department of Energy Environmental Management Consolidated Business C.enter (DOE-EMCBC) and The 

Boeing Company, Contract No. DE-AC03-99SF21530, Modification #108, Section C.4, "Landford Activities: Item 

(g), and Seclion C.5, "Special Sludies.p 

Flle Name: etec_oontract_sf21530_flnal.pdl 

3. U.S. Department ol Labor (DOL) Division of Energy Employee Occupational Illness Compensation (OEEOIC) 

Memorandum, "Atomics lnlemational and Energy Technology Engineering Center,• September 7, 2005. 

File Name: DEEOIC_2005.pdf 

4. Maps, Propulsion Field Laboratory (PFL), Nuclear Development Field Laboratory (NDFL), Santa Susana Field 

Laboratory (SSFL), 1956-1959. 

File Name: PFL...NDFL_ 1956--1959.pdf 

5. U.S. Environmental ProtecUon Agency (EPA), •ssFL Historical Site Assessment (HSA), Final Technical 

Memorandum: Area 1\1, Subarea HSA·5A, npages 3-5. 

Fife Name: 1_Flnal_HSA·5A__ TM_ Text_ 12_2011.pdf 

6. Rockwell lnlemational, "Rocketdyne: 30 Years of American Excellence,• commemorative book issued by 

Rockwell International. 

File Name: Rocketdyne_Bowl_30YearsExcellence.pdf 

7. Internal Leiter, Rockwell International Energy Systems Group (ESG), Re: "One-Quarter-Ton -Per-Hour Coal 

Hydropyrolysis Conversion Test Facility. nseptember 15, 1978. Jeffs-Iacobellis. Page 2, Paragraph 5, "Proposal/ 

File Name: HDMS100012824.pdl 

8. Energy Technology Engineering Center (ETEC) Site Map, c. 1991. 

Fife Name; Area_lV_Bowf.pdf 

9. EEOICPA Case ID Numbers: [Redacted] 

Employees participated in Area I Coal Gasification at The Bowl/ Area IV related facilities 

10. Internal Letter, Rockwell International - Atomics International I ERDA. Kniley (Al) - Wein ch (ERDA). July 2, 1975. 

File Name: ERDA_7_2_1975.pdl 

11. Energy Research & Development Administration (ERDA) Contract No. E(49-18)·2342, ERDA Divisions of 

Procurement and Coal Conversion & Utilization with Atomics International, March 8, 1976. 

File Name: Responsive_Documents_H0_2015_01601_F _Bowl_ERDA.pdf 

12. Quarterly Progress Report, Rockwell lnlemalional Energy Systems Group (ESG) for U.S. Depar1ment of Energy 

(DOE), 'Coal Hydrogasificalion Process Development, October 1, 1980 - December 81, 1980, • DOE Contract No. 

DE-AC01-78ET10328. Page 9. 

File Name: Rockwell_ESG_ 1981.pdl 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 27 of 30 
13. Bechtel National, Inc., "Reactor Performance During Rapid-Rate Hydrogasification of Subbituminous Coal, "by M. 

Epstein, T.P. Chen, and M.A. Ghaly. 

FIie Name: 23_3_Miami Beach_09-78_0168.pdf 

14. Rockwell International Energy Systems Group (ESG), "Experimental Investigation of Peat Hydrogasilication," by 

F.D. Rainier, L.P. Combs, and A.Y. Falk. 

File Name: Vol-24_3-2005.pdf 

15. Rockwell lntemational, Energy Systems Group, Company Publication, c. 1970's. 

File Name: Energy_Systems_Group.pdf 

16. Rockwell International Action Memorandum, "Steam Accumulator Blowdown Evaluation Rig Large Scale Steam 

Valve Test Action Description Memorandum," 1990. 

File Name: HDMSP00019780.pdl 

17. U.S. DOE Office of Environment, Safety and Health, "Tiger Team Assessment, Energy Technology Engineering 

Center," 1991. ETEC Site Map - Area IV/ Area I, The Bowl, page 28. 

File Name: DOE_EH-0175_ES&H7 Tiger_Team_Assessment_of_ETEC.pdf 

18. Rockwell International, Environmental Protection, "Report of Telephone Conversation," Bill Flynn, Air Quality 

Engineer, Ventura County Air Pollution Control District, October 13, 1991. Boeing North American Document 

#BNA00293309. 

File Name: HDMSe0042S825.pdf 

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Appendix I, Figure 1-A, page 1-58 I Appendix II, page 11-61 ). Boeing North American Document #BNA01261268. 

File Name: HDMSe00413923.pdl 

20. Boeing North American Document#: BNA040606123. "Bowl Area: Bowl Retention Pond, Bowl Skim Pond, and 

Bowl Test Stands, "November, 1992. 

File Name: HDMSp01739799.pdf 

21. Boeing North American Document#: BNA01375901. Page 3 (Bowl, Area I) I Page 28 (Building 4005, Area IV). 

File Name: HDMSe00399178.pdl 

22. Boeing North American Document#: BNA01837452 

File Name: HDMSE00375150.pdf 

23. Pratt & Whitney • Rocketdyne: "Department of Energy (DOE) Advanced Single Stage Gasifier Development 

Program,"October 12, 2005. 

FIie Name: PRW_SSG.pdl 

24. Internal Letter, North American Aviation. "Study of Hybrid Motor Operalions, Happy Valley, Santa Susana Field 

Laboratory (SSFL)." Boeing North American Document #BNA 162895. 

File Name: HDMSe00420866.pdf 

25. Rockwell International, 1981. Handwritten notes, "Be [Beryllium] Tanks." Boeing North American Document #: 

BNA02770421. 

File Name: HDMSe00423553.pdl 

26. North American Aviation (NAA) Industrial Hygiene & Safety, "Propellent Engineering laboratory, Area I." Rockwell 

International Document#: SS-SS72-00531. 

File Name: HDMSP00028757.pdl 

27. Internal Letter, Rocketdyne, Re: "Beryllium Contamination, Happy Valley." September 9, 1965. Rockwell 

International Document#: RI-SS72-00504 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 28 of 30 
File Name: HDMSP00028751.pdf 

28. California Department or Industrial Relations Division of Occupational Safety and Health, Radiation Health Unit to 

Rockwell International, August 26, 1963. Boeing North American Document#: BNA02657088. 

File Name: HDMS2410222.pdf 

29. Site Exposure Matrix (SEM) Listing: SSFL Bowl Area - Coal Gasification Process 

File Name: SEM_BowlArea.pdf 

30. E-Mail, Site Exposure Matrix (SEM) Administrator - D'Lanie Blaze, CORE Advocacy for Nuclear & Aerospace 

Workers, August 24, 2016. 

File Name: SSFL_SEM_Bowl_Removal.pdf 

31. Freedom of Information Act (FOIA) #790488. CORE Advocacy for Nuclear & Aerospace Workers, 2015. File 

Name: FOIA_790488.pdf 

This oocurr;ont was 5u~rrntte-d ,.'l honor of S;1nla S,1sar:a F:e:d Lahorn!ory (SSFl) Gmp!oyees 

,,,f:ose contr,b:.,1·ons !o the Sp,)Ce R2.c0 anti Co!d \//ar are aese1111:"!g of 2.ckno;•/iecgernent 

purs,rnnt !o \he Ene·9)' E:mpio:,·ea Occ11pa!,0•1nl ::1ness Cc1mpe11s;:;1,on P1091:1m (EEO!CPA) 

;:i:-id crnag,u£>iil wrth c'ou.nnenled s,ti~ . .:ir.c! coc,tract0f history, 

CORE Aj1·N·acy fo; Nuc!ear & Aerospace ',Vo,-r:1;1s r.on:ws 11,e 1nemo,-,, of 

U.W. Hopsor, - R,x;,:efrnan: S3n10 S:1s.,1r.c1 F,e'.d L1bo·e10,f. Sa1urn V / SNAP Pro91a;n~ 

DOE-ETEC Area I Operations at The Bowl, SSFL Page 29 of 30 
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DDE-ETEC Area I Operations at The Bowl, SSFL Page 30 of 30